Viċi Chairman ta' Alternattiva Demokratika – AD The Green Party

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The Chamber of Architects has taken the Planning Authority to task on the piecemeal local plan reviews that it has been churning out, one at a time. The latest tirade was with reference to a partial review of The Grand Harbour Local Plan (originally published in 2002) specifically with respect to a Marsa Park Site.

We have just concluded a public discussion on a Masterplan for Paceville, which was shredded by public opinion and sent back to the drawing board.

Earlier, we had the Planning Authority itself contesting whether Local Councils, NGOs and the Environment and Resources Authority had a right to contest the decision to permit high-rises in Townsquare Sliema and in Imrieħel.

To make matters worse, instead of consolidating the environmental regulatory functions of the state, this government has opted to deliberately fragment them, thereby ensuring their reduced effectiveness by design. In a small country such as Malta, it pays to have one consolidated authority directed by environment professionals through whom land use planning responsibilities should be accountable.

Land use planning needs to be more focused but holistic in nature. The Chamber of Architects aptly makes the point that focusing the efforts of the partial review of the Grand Harbour Local Plan specifically on “a Marsa Business Park” without considering this within the context of a much needed regeneration of Marsa would be a futile exercise. The decay of Marsa as an urban centre needs to be addressed at the earliest opportunity and this will not be done through piecemeal local plan reviews but through comprehensive planning “which ought to include community needs, road transport re-alignment, environment improvement and flooding mitigation measures”.

These are the basic issues which should be addressed by a local plan review concerning Marsa. Tackling major infrastructural and social problems facing the Marsa community should take precedence over any proposal for the redevelopment of the Marsa Park site. It is the whole of Marsa that should be addressed and not just one tiny corner.

The partial local plan review is ignoring the local community, just like its cousin the Paceville Masterplan did some months ago. Many years ago we learned that “planning is for people”. This seems to be no longer the case as, according to the Planning Authority, planning is apparently for business hubs, high-rises and, obviously, for developers. They seem to be very well connected, thereby ensuring that they occupy the first items of this government’s land use planning agenda.

Marsa has been forgotten over the years. With the closure of the Marsa power station now is the appropriate time to consider the various accumulated impacts on the Marsa community in order that an integrated approach to addressing them is identified. Planning is for people. That means that the Marsa community should be actively involved when these plans are being formulated, including at the drawing board stage. Land use planners should stimulate the Marsa community to speak up and involve itself in drawing up a blue print for its future.

The regeneration of Marsa is an urgent matter which should not be left unattended.

Going by the information available on the increased incidence of various types of cancers, both common and rare types, it is evident that the accumulated environmental impacts originating from human action is exacting its toll. Few make the link between the increased incidence of rare diseases,cancers and environmental neglect accumulated over the years.

Over the Christmas period, as a result of the never-ending humanitarian operations of the Community Chest Fund, we hear of the ever-increasing demand on state resources by those struck by cancer. The demand is such that the resources of the state have to be supplemented by the annual telethon which this year raised a record €5.5 million.

The advertising blitz on the switching over of Malta’s power generation from one dependent on heavy fuel oil to natural gas informs us that air quality in Malta will improve substantially as a result. This statement is only partially correct as the major contributor to Malta’s poor air quality was not power generation but the ubiquitous and exponential increase of cars on our roads.

The cars on our roads are part of the real “cancer factory” in operation on Maltese territory.

As is evidenced by the substantial investments channeled towards the improvement of the road infrastructure, it is clear that the political will to address this issue is very weak. Improved road infrastructure, such as the construction of flyovers to ease traffic congestion, will only increase the dependence on cars. In the long term, this improvement to the road network will hamper the drive to shift custom to public transport. Consequently, it will serve to further increase cars on our roads and will hence contribute to an increase in the output of the “cancer factory”.

Public transport has been improved as is evidenced by a gradual increase in its use. Various initiatives to encourage the use of public transport have been introduced. However, the Maltese state is sending conflicting signals when it simultaneously speaks in favor of public transport yet invests heavily to facilitate the continued domination of our roads by private cars.

Lack of adequate environmental protection in the past has contributed to an ever-accumulating environmental deficit which in turn will lead to total and complete bankruptcy as no one is in a position to bale out Mother Earth.

Environment protection is multifaceted. Addressing the different waste streams and seriously plotting the path to the 2050 zero waste targets established by Malta’s Waste Management Strategy would definitely signify that we are in earnest. However, it is certainly not enough. What about the excessive use of pesticides which still end up contaminating our food chain? Or what about our water table, which in addition to being depleted is also contaminated with pesticides and fertilisers?I could go on and on with a never-ending list of examples.

The environmental deficit is constantly on the increase. Each generation creates additional environmental impacts without in any way adequately addressing the accumulated impacts handed down by the previous generations. Governments are worried by economic deficits, yet few seem to be worried by the accumulating environmental deficit. We are using the earth’s resources as if tomorrow will never come.

No one will bail us out from the consequences of this deficit, yet nature has its own way of extracting its dues. Climate change, the collapse of agriculture in various countries and a higher incidence of common and rare forms of cancers are all different forms of payment which nature is extracting. These bills can only be avoided (in the long term) if we switch back to operating in a manner which is compatible with nature.

“Tall buildings cannot be avoided in our times. The choice we have is whether to control them or else whether to put up with their future growth.” These were the concluding comments of a report drawn up by Professor Mir Ali from the University of Illinois at Urbana-Champaign USA after a visit to Malta in 2008 during which he met with and advised MEPA on the future of tall buildings in Malta.The report is entitled Urban Design Strategy Report on Tall Buildings in Malta.

Professor Ali’s report contains recommendations most of which are as relevant today as when they were originally drafted. Central to these recommendations, way back in 2008, was the need to draw a master plan addressing tall buildings and their impacts. “Lack of a master plan,” Professor Ali stated, “results in uncontrolled developments and unpredictable impacts on urban life.” The developed master plan, Prof. Ali emphasised, should be “for Malta as a whole and for the selected sites for tall buildings, individually.” Drawing up such a master plan with a reasonable level of detail will take time to carry out, a considerable portion of which should be utilised in consultation, primarily with the residents to be impacted. Certainly much more time would be required than the November 2016 target indicated by the government earlier this week. A moratorium on the issuing of any development permit for high-rises until such time that a master plan has been discussed and approved would be a very reasonable course of action.

Professor Ali considered six sites, which were indicated to him by MEPA, as having the potential of hosting high-rise development. He proposed the following rank order : Qawra, Gżira, Tignè, Paceville, Pembroke and Marsa. Such a ranking order by Prof. Ali is qualified by an emphasis on the substantial infusion of public monies which is required. Prof. Ali commented that if the number of sites are reduced to less than six it would be much better for Malta.

Professor Ali made a number of incisive remarks.

There is a need for an objective market and feasibility study for each project, which study should include the life cycle cost of the project. In view of the high vacancy rate of existing residential units, Prof. Ali queried the kind of occupancy expected of high-rises. Failure of high-rises will impact the economy of the whole of Malta which has no safety valve because of its size and lack of adequate elasticity, he stressed.

An efficient public transport is a fundamental requirement for the Maltese islands irrespective of whether high-rises are developed or not. But for the success of tall buildings “an integrated sustainable public transport system” is absolutely necessary. Yet, surprise, surprise, Professor Ali observed that “there is no efficient public transport system that is efficient and that covers the whole of Malta”

Sounds like familiar territory!

Infrastructural deficiencies must be addressed. If the existing infrastructure is inadequate or in a state of disrepair it must be upgraded and expanded to meet future needs. Tignè residents in Sliema have much to say about the matter, not just with reference to the state of the roads in the area but more on the present state of the public sewers! Residents of the Tignè peninsula are not the only ones who urgently require an upgrade of their infrastructural services. Residents in many other localities have similar requirements.

Social and environmental impacts of tall buildings must be considered thoroughly at the design stage. However Maltese authorities have developed the habit of ignoring the social impacts of development projects. In addition, it is very worrying that, as reported in the press earlier during this week, Prime Minister Joseph Muscat does not seem to be losing any sleep over the matter.

People living in a low-rise environment consider high-rises as intrusive. Unless public participation is factored in at a very early stage through planned beneficial impacts on the community in terms of economic benefits, upgrade of services and the general benefits of the redevelopment of the surroundings, such projects do not have a future.

The upkeep of high-rises is quite a challenge which requires skills that are different from low-rise buildings. Notwithstanding changes to the relevant provisions of the law, there already exist serious difficulties in bringing together owners of low-rise multi-owned properties in order that they can ensure that maintenance of such properties is addressed. The challenge of high-rises is exponentially more complex.

The above is a snap-shot of Prof. Ali’s report. From what I’ve heard from a number of people who met Professor Ali, he was more vociferous in his verbal utterances. Unfortunately, his advice has been largely ignored.

20 January is the closing date for the submission of expressions of interest in response to the call by the Privatisation Unit for the setting up of a Motorsports complex in Malta.

During the press conference that launched the call on 29 September, Parliamentary Secretary for Sport Chris Agius emphasised the fact that the choice of location was up to the investors presenting the submissions, even though several sites were proposed in the consultation process leading up to the call for expressions of interest.

However, Sam Collins, writing on 25 April last year on an online motor-racing guide, under the heading Malta eyes Formula 1 with new circuitstated that a “110 hectare parcel of land has been earmarked for the development.” It is pretty obvious that the as yet unidentified “110 hectare parcel of land” to be used for this proposed motorsports complex will be situated outside the development zone (ODZ). Each hectare consists of 10,000 square metres, meaning that 110 hectares equals one million, one hundred thousand square metres.

Sam Collins describes the proposal in this manner: “The government documents relating to the circuit’s development point out that part of its purpose would be to attract major international racing series, including Formula 3 and similar classes. The proposed facility would also include facilities for concerts, conferencing and a racing school. A hotel and museum of motoring and transport heritage would also be built on site. Road safety and driver training would play a major part in the facility’s layout, with a dedicated area for these activities. A CIK Kart circuit would also be built alongside the main track.”

The basic question which had to be addressed – but which most obviously has not been addressed so far – is whether Malta can afford to waste this much land. The answer, in my opinion, irrespective of the number of motor-racing car enthusiasts on the island, is clear and unequivocal: Malta cannot waste any more of its limited land.

The sites that have been possibly earmarked are limited in number, as Malta’s size does not present too many options and the impact of the selected site will be substantial, irrespective of its current use.

Development on the parcel of land selectedcould have a substantial impact on areas of ecological importance that are protected either in terms of local policy or else as a result of EU or international commitments. Knowing that most of the undeveloped land along Malta’s coastline from Bengħajsa right up to Ċirkewwa is protected for ecological purposes, this could be the case, particularly if the identified parcel of land is close to the coast.

The impact could be further increased in view of the possible proximity of the selected parcel of land to residential areas. A specific area, mentioned consistently through the grapevine, would lump these impacts on Malta’s political south, further adding to the disregard for residents’ quality of life in the region accumulated over the years.

There are, therefore, three issues on the basis of which the proposed facility is objectionable: firstly, that Malta is too small for such a development; secondly, that the environmental impact will be substantial and thirdly, that the neighbouring residents’ quality of life, as well as biodiversity and natural resources, will be bartered for short term economic gain.

Depending on the precise eventual location, it may be possible to mitigate and reduce the impact on residents. However, it is most probable that a reduced impact on residents would signify increased impact on natural resources and biodiversity. In my opinion, this signifies that even on the drawing board the project should have been a non-starter.

In recent months we have had the Żonqor “University” debacle. A major sticking point in that case was that the original proposal was to use land situated outside the ODZ and public opinion’s unifying reaction was “No to ODZ development”.

The Parliamentary Opposition, both inside and outside Parliament, took a clear stand against the ODZ Development proposed at Żonqor. Yet in the case of the proposed motor track facility, the Opposition Spokesperson on Sport, David Agius, was invited to be present when the call for expressions of interest was launched. His presence confirms that, notwithstanding Simon Busuttil’s solemn declarations on the sanctity of ODZ land, the proposal for the (ODZ) motor track facility enjoys bipartisan support.

When the current Gozo Channel tunnel debate was initiated around five years ago, the then Minister Chris Said went on record to emphasise that the proposed tunnel, to be bored under the seabed would cost approximately €150 million. This estimate has now been upped to €300 million.

This is one of the basic assumptions underlying the study commissioned by Transport Malta, together with the Gozo Business Chamber, and carried out by E Cubed Consultants Ltd, commonly referred to as the “economic and financial feasibility study”.

The study makes interesting reading as it considers the economics of the so-called permanent link between the islands of Gozo and Malta. I respectfully submit that the conclusions of this study are as valid as the basic assumptions which underpin it.

I draw the attention of readers to the fact that proposals for various tunnels are currently under consideration in other countries.

The first is the proposed Trans-Pennine tunnel, intended to improve the transport links between Sheffield and Manchester in the UK. The ambitious 18- mile (29km) tunnel would be built under the A628 Woodhead Pass. After having established that the geology of the Pennines was suitable for such a project, it was estimated that the approximate cost would be a staggering £6 billion (€8.40 billion).

The second UK project is the much-debated and controversial tunnel at Stonehenge. Intended to upgrade the A303 road, it is projected to have a length of 1.8 miles (2.9 km) and is currently estimated to cost £490 million (€700 million).

The estimates for the proposed tunnels in the United Kingdom indicate that the cost of a 10 km tunnel would exceed the €2 billion mark, even before taking into account the fact that excavating below the seabed would cost substantially more. In addition, the Danish/German tunnel indicates a pro-rata cost of €4.7 billion for a 10 kilometre tunnel.

In addition, the geological parameters below the Gozo Channel are still largely unknown: geological studies have to be carried out and examined in detail in order to establish the facts. Without these facts, the basic information necessary to take essential design decisions is still unavailable. What is known is worrying enough: the presence of active geological faults running right through the proposed route of the tunnel.

The study’s conclusions – that the proposed tunnel is economically viable – have been reached prior to the carrying out of geological studies. Even the estimated costs used in the economic viability study have been established before these essential geological studies.

In this type of project, no estimate of costs can be precise – especially if it is not based on adequate and essential information.

This indicates that the conclusion of the economic viability study was premature.

In addition to the geological studies, additional important (and essential) studies have (as far as is known) not yet been commissioned. These include studies on the environmental impact, business impact and social impact.

Once concluded, such studies will inevitably point to other issues that will require detailed consideration, including the extent to which the projected permanent link between Malta and Gozo will toll the death knell for holiday accommodation in Gozo: hotels, flats and farmhouses.

The above indicates that, unless the promoters of the tunnel have some cast-iron guarantee of substantial discounts on the costs, the proposal is a non-starter even before any consideration of the environmental, business and social impact. It is about time to begin serious work on the practical alternative: a fast ferry service between Gozo and the Grand Harbour.

Gozo’s connectivity issues are considered as a problem when in reality they define Gozo and determine its distinct features. Unfortunately, in this respect both the government and the opposition have developed a tunnel vision, that is they tend to focus on just one view and ignore everything else.

The latest twist in the current debate is the declaration by the Finance Minister in his budget statement earlier this month that the feasibility study commissioned by Transport Malta, together with the Gozo Business Chamber has been concluded positively and that the next step would be the commissioning of a technical and geological study relative to the projected tunnel across the Gozo Channel.

Transport Malta, prodded by the Gozo Business Chamber, seems to be bent on putting the cart before the horse as it is inconceivable how a feasibility study could be concluded without first having identified all the geological issues and examined them in detail. Knowing that the Gozo Channel contains a number of geological faults, including active ones, leads to the logical preliminary conclusion that geological studies of the area proposed to be tunnelled could have a substantial bearing on the technical parameters of the project. This would include the specific route to be selected, the actual works to be carried out and the costings. The geological studies could also lead to a technical recommendation to select an alternative solution other than boring a tunnel below the seabed .

When the PN-led government placed the issue on the national agenda, former Minister Chris Said gave his guesstimate that the tunnel would cost in the region of €150 million. We have recently been informed that this guesstimate has increased substantially to between €250 and €300 million.

These guesstimates are on the low side, because when the geological issues have been examined the estimate could well shoot up to over €1 billion- this being around 4 times what has been taken into consideration in the so-called “feasibility study”.

These type of project very rarely follow estimated costs. The tunnel linking the Marsa and Delimara powers stations in Malta, for example, overshot its projected costs by around 100% due to the absence of adequate geological information. As a result, parts of the tunnel caved in during works, necessitating substantial additional work, including redirecting parts of it. On the other hand, expenditure on the Channel Tunnel linking Folkestone in Kent to Coquelles near Calais exceeded the projected estimates by around 80% notwithstanding the availability of detailed geological studies.

Last week, one of the Sunday newspapers referred to a survey carried out by the Gozo Tourism Association which indicates that 64% of tourism operators in Gozo are adamantly against the proposed tunnel because the direct result of this would be to render Gozo as an appendage of Malta. Gozo would be transformed into a one- day destination, just like most of the other tourism attractions spread over the Maltese islands.

Gozitan tourism operators have a very valid point, as the direct result of this tunnel vision is that Gozo would be transformed from an island into a remote village. Most hotels in Gozo as well as the flats and farmhouses available to let, could then require the identification of another use.

This matter has not yet been examined and yet it is fundamental to the decision-making process and should have been the first step in the whole exercise.

All this muddle and I have not yet commenced discussing the environmental impacts of the proposed tunnel!

The tunnel will generate large quantities of rock which require disposal. The precise amount would depend on the route to be followed (and consequently the length of the tunnel) as well as the selected design (the cross sectional area) and could be anything between one and two million cubic metres of fragmented rock.

In addition, the proposed point of entry of the tunnel at Iċ-Ċumnija on the outskirts of Mellieħa, would most probably be accessed through a new road network in the area immediately behind the Għadira Nature Reserve and bird sanctuary. This means that all the environmental issues which were discussed when the proposed TEN-T network was being debated will once more be of relevance.

There are many other ways through which Gozo’s connectivity issues can be addressed and there are certainly more cost effective ways than the proposed tunnel. The costs to be considered are not just financial: they include social and environmental costs, which should be considered on the drawing board and not as an afterthought.

This is the problem with the tunnel vision – you just have one view, excluding all the others.